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← 84 TC 920 - Freesen v. Commissioner

Freesen v. Commissioner’s Empirical Analysis

1985

Citation profile

16
cited by 16 later decisions
May 1991
most recently cited

2 federal appellate ·

Relationships

Relies on Welch v. Helvering · Thor Power Tool Company v. Commissioner of Internal Revenue · Helvering v. Winmill · Commissioner of Internal Revenue v. Portland Cement Company of Utah · Luna v. Commissioner

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “the parties shall make a general accounting of net profits and loss after allocation of costs of the joint venture. The first $1,100,000.00 of net profit shall be paid to Equipment Co. The next $2,200,000.00 of net profit shall be paid to [Freesen]. Any net profit over $3,300,000.00 shall be divided equally between the parties.... Losses shall be shared on the same proportional basis as profits are to be distributed.”
    1 later decision quote this exact passage
  2. “for advances on equipment usage and the actual costs for service personnel, insurance, taxes, fuel and lubricants, and parts replaced or repaired on vehicles repaired or replaced under the services and maintenance provisions”
    1 later decision quote this exact passage
  3. “the term of the lease (taking into account options to renew) is less than 50 percent of the useful life of the property.”
    1 later decision quote this exact passage

How this case has been treated — in progress

Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.